The Matter File
Why it Matters
Open the shared drive at a busy small firm and you may find a folder of files named scan0001, Doc1, and demand FINAL2. Every name made sense to the person who saved it, and none of them helps the person who has to answer the client’s next question. Florida’s rules follow that folder from the first intake note to the day it is destroyed. The firm must guard it wherever it is stored, keep the client informed from it, and give back what belongs to her when the case ends. You will take one client’s file as one firm kept it and turn it into a record anyone at the firm could work from.
Current Context
In April 2026, Docketwise, a cloud case management system built for immigration lawyers, began notifying its law firm customers’ clients (opens in a new tab) that someone using valid login credentials had copied law firm records holding their personal information. Legal industry reporting on the state filings (opens in a new tab) put the number of people affected at more than 116,000, with Social Security numbers, passport numbers, and health information among the data. In July 2026, a proposed class settlement (opens in a new tab) was announced in Emerokwam v. 8am LLC, a suit against the vendor in Miami-Dade County, where the court has set a final approval hearing for October 19, 2026. None of those clients chose the vendor; their lawyers did, and under Rule 4-1.6(e) and Ethics Opinion 12-3 that choice is part of how a firm protects what its clients tell it.
Key Concepts
Matter Record
One matter’s facts in a practice management system: the client, the other parties with their lawyers and insurers, the court and case number, the key dates, and the responsible lawyer. Documents, emails, notes, and deadlines attach to it, so it is where anyone at the firm starts. The firm’s conflict checks search these names, so a party missing from the record is a party the next check cannot find.
Naming Convention
A firm’s written rule for naming files, applied the same way by everyone. A common pattern starts with the date, written year-month-day so files sort in order, then the matter, the kind of document, and a short description, with a version marker on drafts. A name like “demand FINAL2” fails, because no one can tell from it whether a later version exists or which one went out.
Document Management System
Software that stores a firm’s documents by client and matter, with a profile for each document, a history of its versions, and permissions that set who may open it. Version control keeps every draft but marks one as current, so no one has to guess which file is final. Practice management systems carry a simpler form of the same tools, and a shared drive with a naming convention is the form without software.
Client Portal
A secure site, usually part of the practice management system, where a firm and its client exchange messages and documents that save to the matter. Rule 4-1.4(a) requires a lawyer to keep the client reasonably informed about the matter and to comply promptly with reasonable requests for information. A paralegal’s update can report facts and dates the lawyer has approved, but a prediction about the outcome, or advice on what the client should do, has to come from the lawyer.
Cloud Storage
Keeping client files on a provider’s servers and reaching them over the internet, as practice management systems do. Rule 4-1.6(e) requires reasonable efforts to prevent unauthorized access to client information, and Ethics Opinion 12-3 allows cloud storage when the lawyer has researched the provider. That research covers the provider’s duty to keep the data confidential, its security, the lawyer’s own access to the data, and what happens to the data when the service ends.
The Client’s File
In Florida the file a lawyer builds is the lawyer’s property, as the Fifth District said in Dowda & Fields, P.A. v. Cobb, but the client’s own papers and property in it are hers. Rule 4-1.16(d) requires a lawyer, when the representation ends, to surrender the papers and property the client is entitled to. Ethics Opinion 88-11 (Reconsideration) adds copies of useful material on reasonable request, and says a client is generally not entitled to internal notes, drafts, or another client’s information.
File Retention
Florida sets no general period for keeping a closed file. Rule 5-1.2(f) keeps trust records six years after the representation ends, and Rule 4-1.5(f)(5) keeps a contingency fee contract and closing statement six years after the statement is signed. For everything else, Ethics Opinion 81-8 lets the contents decide, and a firm tries to reach the client before it destroys a file.
Electronic File
Ethics Opinion 06-1 lets a firm keep files only in electronic form, unless a statute or rule requires an original, the original is the client’s, or destroying the paper would hurt the client’s interests. The electronic copy must be readily reproducible and protected from accidental change, decay, or loss. A scan of a client’s receipt belongs in the file, and the receipt itself goes back to her.
Resources
- Zubieta matter file (The twenty files in Temko Eden’s shared folder “Zubieta stuff,” as the firm has kept them since October 2025. Unzip it before you start; three of the files are in a subfolder. One file, IMG_4471.jpg, is a photo of Kestrel Home Center’s customer incident report, customer copy. Its text reads: store, Daytona Beach; date, 10/18/2025; time, 11:20 AM; location, Aisle 14 (cleaning supplies); customer, Maria Zubieta; what happened, “Customer slipped on liquid on floor near bottom shelf. Liquid appeared to be blue floor cleaner from a leaking bottle. Customer states left wrist pain.”; first aid, “Ice pack offered. Customer declined ambulance, left with family member.”; area cleaned, 11:35 AM; manager on duty, R.T.; witnesses, none listed; customer signature, M. Zubieta.)
- Matter file workbook (Nine emails about the case on the Inbox sheet, and the sheets you fill in: the Matter Record, the Naming Convention, the Document Index, the Communications Log, and the Closing Plan. It opens in Excel or Google Sheets.)
- Clio Manage free trial (opens in a new tab) (A seven-day trial of a practice management system, with matters, contacts, documents, and a client portal. It needs no credit card but asks for a phone number. Start it the day you begin Part 1, or work in the workbook alone.)
- Rules Regulating The Florida Bar (opens in a new tab) (Chapter 4 holds Rule 4-1.4 on keeping a client informed, Rule 4-1.5(f)(5) on keeping the contingency fee contract and closing statement, Rule 4-1.6(e) on reasonable efforts, and Rule 4-1.16(d) on what goes back when a case ends. The comment to Rule 4-5.3 covers internet services that store client information. Chapter 5 holds Rule 5-1.2(f) on trust records. Read the current chapter PDFs.)
- Florida Bar Ethics Opinion 12-3 (opens in a new tab) (When a firm may keep client files with a cloud provider, and what to find out about the provider first. Advisory, not binding.)
- Florida Bar Ethics Opinion 88-11 (Reconsideration) (opens in a new tab) (What a lawyer generally must give a client from the file, what a client is generally not entitled to, and when a firm may hold the file for unpaid costs or fees. Advisory, not binding.)
- Ethics Informational Packet: Closed Files, The Florida Bar (opens in a new tab) (The Bar’s answer to how long a firm must keep closed files, the full texts of Opinions 06-1 and 81-8, a model file retention policy, and tips on destroying records safely.)
- How Long Should I Keep Closed Files?, LegalFuel (opens in a new tab) (The Florida Bar’s practice resource center on the six-year rules, returning a client’s originals, and keeping a list of the files a firm has destroyed.)
- Dowda & Fields, P.A. v. Cobb, 452 So. 2d 1140 (Fla. 5th DCA 1984) (opens in a new tab) (A discharged firm’s office file is the firm’s property, though it may hold the client’s property and information the next lawyer needs. The court reversed an order requiring the firm to hand its office file to successor counsel.)
What to Do
Twenty files and nine emails are all Temko Eden has to show for ten months of Maria Zubieta’s case. You sort them into a matter record the firm can work from, answer the client from what the file shows, and plan what happens to every page when the case ends. What you post is the matter file workbook and the client update, in its first draft and its revision.
Part 1: Open the Matter
Temko & Eden, P.A. A three-lawyer firm on Beach Street in Daytona Beach. It still carries the names of its late founders. Dana Whitfield, the managing partner, handles civil litigation and real estate closings. Luis Ortega, a partner, handles family law and probate, and Kim Nguyen, an associate, handles personal injury. Marcy Cole is the legal assistant, Ron Pike is the bookkeeper and office manager, and you are the firm’s paralegal.
The Zubieta matter. On October 18, 2025, Maria Zubieta slipped on floor cleaner in the aisle of a home improvement store in Daytona Beach and broke her left wrist. Kim Nguyen took her case on a contingency fee and sued the store in April 2026. Everything the firm has on the case sits in one shared folder, “Zubieta stuff,” and in emails no one saved to the matter.
Download the Zubieta matter file and the matter file workbook, unzip the file, and read the workbook’s Start Here sheet. Then read every email on the Inbox sheet, oldest first. If you can start the practice management trial in Resources, open a matter for Maria Zubieta there and add her, the store, its insurer, and defense counsel as contacts. The trial lasts seven days, so start it the day you begin. Either way, fill in the Matter Record sheet from the documents and the emails, and where the file says nothing, write that it says nothing. Before you rename a single file, write Temko Eden’s naming convention and folder list on the Naming Convention sheet. Run the Naming Convention Stress Test on them, and revise until the rule gives one answer for every document the prompt invents.
Part 2: Work the File from Hell
Open all twenty files, including the three in the subfolder, before you decide anything about any of them. Some are not what their names say, and at least one does not belong in this matter. For each file, fill in its row on the Document Index: what it is, its date, its folder, its new name under your rule, and its status. Then rename the files and put them in their folders, in the practice management system or on your own computer. For any file whose status is not Keep, the Note column says what you did with it and why. For a document from another client’s matter, the note also says whom you told. Last, log each email that belongs in this file on the Communications Log sheet, with what it adds to the Matter Record.
Part 3: Answer the Client
An email from Kim Nguyen, August 6, 2026. Maria emailed last night asking for news, and she’s right that we owe her some. Please send her a status update through the client portal. Here is where things stand: the defendant’s insurance company has responded to the demand letter, discovery is underway, and her deposition is being scheduled for next month. Ask her which of the three dates Claire offered she can make, and tell her I will meet with her before the deposition to prepare. She also needs to come in before August 21 to go over her interrogatory answers and sign them in front of a notary. Don’t answer her question about taking an offer, or anything else about what the case is worth; tell her I’ll call her about that this week. Send me your draft before it goes out.
Draft the portal message to Maria Zubieta in 150 to 250 words, from what the file shows and not from Kim’s email alone. It must be informative and clearly written, and it must not include any legal advice or any opinion about how the case will turn out. Check every date and fact in it against your Matter Record. Then run the Communication Reviewer on your draft, decide which of its suggestions to accept, and revise. Log the revised message as the last entry in the Communications Log.
Part 4: Plan the Closing
Fill in the Closing Plan sheet for the week the Zubieta case ends, however it ends. Say what goes back to Maria Zubieta and how, what the firm keeps and for how long, what it may destroy at closing, and what happens to the electronic file. Name the rule, the ethics opinion, or the clause of the fee agreement behind each answer, and say so where the answer is the firm’s own choice. Read Opinion 88-11 (Reconsideration) and the Bar’s Closed Files packet first. Then run the Closing Plan Checker with the texts it asks for, and correct any row the texts do not support.
Part 5: Post Your Deliverables
Create one new discussion thread. Attach the matter file workbook with every sheet filled in, and your portal message to Maria Zubieta in both versions, the draft and the revision. Add three to four sentences explaining the most important changes you made and why. If you built the matter in a practice management system, attach screenshots of its details, its documents, and its communications.
Part 6: Share Chat Link
Include one AI chat link with a 1–2 sentence explanation of what the conversation shows and why you chose to share it.
Suggested AI Prompts
Use these prompts as a starting point, then adjust them to fit your goal. Strong prompting develops through trial, revision, and testing. It’s a foundational skill that grows into more advanced AI work such as context engineering and agent-based workflows.
Naming Convention Stress Test
I am a paralegal writing a file naming convention for a small Florida law firm. I will paste my rule and my list of folders. Test them. Invent fifteen realistic documents and messages from a personal injury case, including a scanned signed contract, two drafts of the same letter, a court filing with an e-filing stamp, a photo from a client’s phone, an email with attachments, and a document that belongs to a different client. For each one, apply my rule and give the file name and folder it produces. Where my rule gives two possible answers, or none, stop and show me the gap instead of choosing for me. Do not rewrite my rule; I will revise it myself. Wait for me to paste the rule.
Asking the model to invent cases and run your rule on them is stress-testing, and it finds the gaps before twenty real files do. Telling it to show each gap rather than fill it keeps the rule, and the judgment in it, yours.
Communication Reviewer
Act as a supervising attorney reviewing a paralegal’s draft client communication. I will paste in an email or letter I have drafted to a client. Evaluate it for professionalism, clarity, tone, and, most importantly, whether it stays within the bounds of a permissible client update or inadvertently crosses into legal advice. Identify any language that could be read as an opinion about the case outcome, any jargon that should be replaced with plain language, and any missing elements (such as next steps or a prompt to call the attorney with questions). Provide a revised version with your changes highlighted. Confirm that you understand and ask me to paste in my draft.
Role assignment puts the model in the supervising lawyer’s chair, and naming the line the update must not cross aims its review at the risk that matters most. Treat its revision as a set of suggestions, and accept a change only when you can say what it fixes.
Closing Plan Checker
I am a paralegal planning how a small Florida law firm will close a personal injury client’s file when her case ends. I will paste the texts my plan relies on: Rules 4-1.16(d), 4-1.5(f)(5), and 5-1.2(f) of the Rules Regulating The Florida Bar; Florida Bar Ethics Opinions 81-8, 06-1, and 88-11 (Reconsideration); and the file clause of the client’s fee agreement. Then I will paste my closing plan, one row at a time. For each row, quote the sentence from those texts that supports it, or say that none does. Flag any retention period, deadline, or duty in my plan that the texts do not state, and say whether it could be the firm’s own choice instead. Do not add rules from anything else you know, and do not rewrite my plan. Wait for me to paste the texts.
Source grounding holds the model to the texts you paste, and asking for the supporting sentence turns each verdict into something you can check. A model answering from memory can supply a retention period no Florida rule sets, and a plan built on it destroys files too early or keeps them for no reason.