FEHA Constructive Discharge — MSJ Review Case Study
How a partner-level review tested an associate's summary-judgment draft against the full record before it went out the door.
Outcome Snapshot
Full motion-review workflow. An associate's MSJ draft, tested against the whole record.
A partner needed to review an associate's motion for summary judgment (MSJ) in a FEHA constructive-discharge case before filing. Using Inquisita to authenticate the draft's facts against a 3,228-page record, the review worked through six dimensions from threshold strategy to mechanical fixes and produced a revisions memo written in the partner's voice, ready to forward to the associate.
How it was done — 4-step workflow
Pull the matter context
Before reading the draft, the review pulled the operative documents and matter correspondence from Inquisita so the motion's facts could be tested against the record rather than its four corners.
151 documents · 3,228 pages on handReview across six dimensions
The draft was examined in order: threshold strategy, procedural compliance, evidentiary sufficiency, citation accuracy, internal consistency, and mechanical fixes, with strategy outranking everything else.
Strategy → procedure → evidence → mechanicsAuthenticate the facts and authority
Each cited fact was checked against the underlying documents and each authority tested for whether it was the right case cited with an accurate parenthetical, flagging weak or missing controlling authority.
Every cited fact authenticatedWrite the revisions memo
The findings were written as a partner-to-associate memo leading with the strategic concerns, giving document-by-document revisions and a concrete, assignable next-step list.
Partner-voice memo — forwardable