Case Management and Eval

Per-matter case library, evidence-vetting, and grounded evaluations.

Attorney work product · Draft

⚖ MatterWhitfield v. Delta Supply Co. ▾

employment · ADEA / Title VII ✓ Synced from Drive · 214 documents · Jul 09

Case Management Library Facts & Evidence Evaluations Discovery

Whitfield v. Delta Supply Co.|employment · ADEA / Title VII|filed 2025-02-11|Discovery

Key dates & deadlines

Event	Owner	Due	Status
Opposition to MSJ due	K. Reyes	2025-07-21	8 days
Expert disclosure deadline	K. Reyes	2025-08-04	On track
Discovery cutoff	Team	2025-09-12	On track
Pretrial conference	Team	2025-11-03	Scheduled

Open tasks 4

Task	Assigned	Priority	Status
Draft opposition brief to summary judgment	K. Reyes	High	In progress
Confirm comparator ages — pull from personnel records	Paralegal	High	Open
OCR & classify 2 pending comp-letter pages	Records	Med	Open
Retain damages expert — economic loss model	K. Reyes	Med	Open

Team & billing

Timekeeper	Role	Rate	Hours (MTD)
K. Reyes	Lead attorney	$425	38.4
M. Cho	Associate	$285	52.1
D. Alvarez	Paralegal	$145	27.6

Deadlines sync from the court calendar; tasks and time entries flow to Billables. Case Management is the operational layer; Evaluations is the analytical one.

214 documents|classified into the four indexes|2 need OCR

Client documents 41

Document	Type	Date	Bates	Status
Offer letter — Whitfield employment agreement	Contract	2011-08-14	—	OK
Performance review — 2023	HR record	2024-01-09	—	OK
Termination letter	HR record	2024-06-02	—	OK
Compensation statements 2022–2024 (scanned)	Financial	—	—	OCR pending

Discovery — ours 28

Document	Type	Date	Bates	Status
Plaintiff — Responses to First Set of Interrogatories	Discovery response	2025-05-02	P000001–000048	OK
Plaintiff — Responses to Requests for Production	Discovery response	2025-05-02	P000049–000132	OK

Discovery — opposing · Delta Supply Co. 118

Document	Type	Date	Bates	Status
Defendant — Production Set 1	Production	2025-04-18	D000001–000142	OK
Defendant — Responses to Interrogatories	Discovery response	2025-04-18	—	OK
4 un-OCR'd pages in a comp-letter gap — may be damages-relevant	Unidentified	—	D000098–000101	OCR pending

Pleadings 27

Document	Party	Date	Bates	Status
Complaint (ADEA / Title VII)	Plaintiff	2025-02-11	—	OK
Answer & Affirmative Defenses	Defendant	2025-03-14	—	OK
Motion for Summary Judgment	Defendant	2025-04-30	—	OK

Classification & normalized names are maintained per document (bucket · type · party · date · Bates · privilege). Correspondence backfill from Front and the batch fact-pull run are the next pipeline passes.

Uncontested facts

Whitfield was employed by Delta Supply Co. from Aug 2011 to Jun 2024.¹

Whitfield was 58 years old at the time of termination.²

Delta cited a "reduction in force" as the stated reason for termination.³

Contested facts

Whether the RIF was a pretext for age discrimination.

Our evidence

Two employees under 40 retained in the same role after the RIF.⁴

Their evidence

Contemporaneous budget-cut memo naming the eliminated positions.⁵

Whether the 2023 bonus cap applied to Whitfield's compensation.

Our evidence

Offer letter fixing bonus terms with no cap.⁶

Their evidence

Revised compensation policy circulated in 2023.⁷

Evidence ledger

Exhibit	What it proves	Admissibility risk	Relied on by
P-Ex 3 — Offer letter	Bonus terms & no cap	Low	Contested #2
D-Ex 12 — Budget memo	RIF rationale	Hearsay · foundation	Contested #1
Whitfield Dep. 42:3–18	Employment timeline	Low	Uncontested #1

Unsupported-assertion flags

⚑

Our brief asserts "comparators were substantially younger," but there is no admissible evidence of comparator ages in the corpus. UNVERIFIED — pull and confirm.

⚑

Cite to 29 U.S.C. § 623(a) is not yet anchored to a pulled authority in the corpus. UNVERIFIED — pull and confirm.

1 Whitfield Dep. 42:3–18 · 2 Personnel file, DOB · 3 Termination letter (2024-06-02) · 4 Def. org chart, post-RIF · 5 D-Ex 12 · 6 P-Ex 3 · 7 Def. policy, D000071. Every assertion anchors to a pinpoint quote; anything not in the corpus is flagged UNVERIFIED.

Run an evaluation

Pre-engagement Intake

Assess a prospect before engagement — preliminary strengths / weaknesses, facts still needed, and a draft scope of work. Lives in the Intake console.

Web: strategy-only

Ongoing

Adversarial engine: a blind opposing-counsel pass finds the dispositive weakness, then findings are organized by lens — assertions, evidence, procedural, consistency.

Web: strategy-only · facts corpus-only

Post-case Pilot

Full corpus + outcome → our strong / weak points vs. opposing counsel's play, what we'd do differently, and app-feature suggestions filed to Admin.

Web: none · corpus-only

Reports

Report	Mode	Version	Generated
Post-case evaluation — Whitfield	Post-case	v2	Jul 08
Adversarial pass — MSJ response	Ongoing	v1	Jun 30

Every report is versioned, dated, and stamped Attorney Work Product — Draft. Nothing here is ever emailed; multi-pass runs (advocate → blind adversary → judge) are metered and shown in Ops.