An Inspectable AI Playbook For Pre-Filing Motion Review
Review 5102(d), liability, and Graves Amendment summary judgment motions before filing. The playbook checks the issues plaintiff will attack and links substantive output back to source authority.
Book a walkthrough, install the playbook live, and run it on a real motion within minutes.
The risk
The motion starts from a prior motion. The problem is what gets missed.
Most defense firms already have good templates. The harder problem is issue coverage on the 50th, 80th, or 120th motion: every pleaded injury, category, expert finding, causation theory, exhibit reference, and plaintiff-friendly failure mode still has to be checked.
The review
- Missed body parts or serious-injury categories
- 90/180 treated too generally
- Defense IME findings that create triable issues
- Degeneration opinions that do not address exacerbation
- Treatment-gap arguments plaintiff can explain
- Graves maintenance or entrustment gaps
- CPLR 3212(f) prematurity risk
- Exhibit, NYSCEF, and citation consistency problems
How The Walkthrough Works
The first session is designed to be concrete. We install the playbook into the AI tool you already use and run a motion review together.
Book a 15-minute walkthrough
Bring the AI tool you already use. Claude, ChatGPT, or Codex are all fine for the first walkthrough.
Install the playbook live
We add the NY motor vehicle defense review playbook to your AI environment and walk through what it contains.
Run it on a real motion
We review a public NYSCEF motion or a draft you choose and generate a short opposition-risk audit.
The playbook runs inside the AI tool you choose. DocketDrafter does not receive your documents when you use the local playbook. You remain responsible for your firm's AI policy, confidentiality obligations, protective orders, and court rules.
Pre-Filing Opposition Review
The playbook reads a draft motion from the plaintiff's side and returns a ranked audit: motion-defeating weaknesses, motion-narrowing weaknesses, drafting defects, specific fixes, and clickable authority.
Issue
The bill of particulars alleges lumbar exacerbation, but the motion only argues degeneration and does not address the pleaded aggravation theory.
Plaintiff's attack
Defendant failed to eliminate causation because the expert did not address the pleaded exacerbation theory.
Fix before filing
Add an expert-supported causation section addressing pre-accident records, post-accident imaging, and why the accident did not aggravate the claimed lumbar condition.
You Can Inspect The Playbook
This is not black-box legal AI. The playbook comes with the authorities, topic files, and workflows it applies. If it flags a risk, you can inspect why.
Primary Sources
Insurance Law 5102 and 5104, CPLR 3212, VTL sections, Graves Amendment authority, and New York appellate decisions are bundled into the playbook.
Cases and statutes
Topic Files
Attorney-readable files explain recurring issues like 90/180, treatment gaps, degeneration, admissible form, right of way, unsafe lane changes, and Graves carve-outs.
Issue-by-issue doctrine
Review Workflows
The workflow identifies each ground for relief, routes it to the right issue catalog, checks the draft, ranks the weaknesses, and suggests specific fixes.
Pre-filing motion audit
Built For The Motions NY Defense Firms File Every Week
The same source-linked structure supports pre-filing review across the recurring motion types in New York motor vehicle defense.
5102(d) Threshold Motions
Checks pleaded categories, body parts, IME findings, MRI causation, treatment gaps, 90/180 proof, admissible form, and plaintiff opposition risk.
Graves Amendment Motions
Reviews owner/lessor proof, trade-or-business status, negligent-maintenance allegations, negligent-entrustment theories, and timing risks.
Liability Motions
Maps the facts to VTL duties, right-of-way rules, unsafe lane-change patterns, rear-end presumptions, comparative fault, and CPLR 3212(f).
Some of the Sources Inside
The playbook bundles primary authorities and rule summaries so the review can cite the source behind each risk. These are examples of the authorities the NY motor vehicle defense playbook is built around.
Core threshold authorities
- Insurance Law 5102
Defines serious injury categories, including permanent consequential limitation, significant limitation, and 90/180.
- Insurance Law 5104
Bars non-economic loss unless plaintiff establishes serious injury.
- Licari v. Elliott
Court decides threshold in the first instance; minor limitations are not enough.
- Toure v. Avis Rent A Car Systems, Inc.
Objective quantitative ROM deficits or qualitative assessment can raise a triable issue.
- Pommells v. Perez
Treatment gaps, degeneration, and intervening conditions can defeat causation or permanency if not explained.
- Ramkumar v. Grand Style Transportation Enterprises Inc.
No-fault cutoff or inability to pay may explain treatment cessation.
Recent denial-risk patterns
- Diaz v. Nightingale Bakery & Beverage Distrib., Inc.
Defense experts did not specifically address the 90/180 category for the relevant post-accident period.
- Jaggi v. Munger
Defense failed to eliminate cervical spine, right shoulder, 90/180, and causation issues.
- Rook v. Wood
Defense physician diagnosed accident-related strains and quantified ROM loss.
- Weber v. Kalisky
Defense failed to address pleaded exacerbation of preexisting spine injuries and 90/180.
- Salcedo v. MTA-New York City Tr.
Failure to address pleaded PTSD, postconcussion, psychological, or emotional injuries defeated prima facie burden.
- Ravi S.A. v. Gyebi
Recent First Department PTSD serious-injury decision with different outcomes by category.
Liability, Graves, and motion practice
- CPLR 3212
Summary judgment standard and motion practice baseline.
- VTL 1128
Unsafe lane-change rule: vehicle must remain in lane until movement can be made safely.
- VTL 1129
Following-too-closely rule used in rear-end and chain-collision motions.
- 49 U.S.C. 30106
Graves Amendment preemption for rental and leasing owner liability.
- Graham v. Dunkley
Leading Second Department decision applying Graves Amendment preemption to VTL 388 claims.
- Reifsnyder v. Penske Truck Leasing Corp.
Useful template for maintenance-record and inspection proof on Graves dismissal.
Custom review playbooks
Start with the base playbook. Build your firm's version when it proves useful.
The free walkthrough uses the base NY motor vehicle defense playbook. If your firm likes the workflow, we can adapt it to your preferred authorities, recurring arguments, partner review notes, carrier requirements, and formatting conventions.
The goal is to turn your firm's motion know-how into a private review asset that associates can use before partner review and partners can use to check drafts faster.
Full drafting automation can come later. The first step is proving that the review playbook catches useful issues on real work.
Free first walkthrough
- Walk through the issue catalogs and source files
- Run a sample pre-filing review on a public or redacted motion
- Inspect the authority links behind each flagged risk
- Customize the playbook with your preferred cases or phrasing
- Convert your firm's motion standards into a private review playbook
- Decide whether the review is useful before discussing broader rollout
Common Questions
Is this drafting software?
The first use case is review. Take a motion your firm already drafted and audit it before filing. Drafting is available later, after you trust the playbook.
Does it make up cases?
The playbook is built around bundled cases, statutes, topic files, and issue catalogs. Substantive outputs link back to source authority where available.
Can we see what it is relying on?
Yes. The playbook is attorney-readable. We can show the issue catalogs, topic files, source files, and review workflow directly.
Can this use our firm's standards instead?
Yes. The base NY motor vehicle defense playbook is a starting point. We can adapt it to your firm's preferred authorities, recurring arguments, partner review notes, formatting conventions, and carrier-specific requirements.
Do we need to change our case management system?
No. This is not a replacement for TrialWorks, CARET, Filevine, or your document system. Start with one public or redacted motion.