The corporate facts can be common, but each person needs an individual showing of special knowledge of the organization's products, services, application, or advanced processes and procedures. A letter that repeats the same paragraph under different names invites the conclusion that the knowledge described belongs to the department rather than to any individual.
Write each claim from that person's work
Start from what the individual actually does and let the sentences differ naturally. Two colleagues on the same platform will have handled different failures, written different procedures, and trained different people. Capture those particulars.
Where two files genuinely overlap because the work overlaps, tell counsel rather than manufacturing a distinction, since an invented difference is worse than an admitted similarity. Start from what each individual actually does and let the sentences differ naturally, because two colleagues on the same platform will have handled different failures, written different procedures, and trained different people. Capture those particulars rather than smoothing them.
The corporate facts can be common, but each person needs an individual showing of special knowledge of the organisation's products, services, application, or advanced processes and procedures, and a letter repeating one paragraph under different names invites the conclusion that the knowledge belongs to the department rather than to anyone in it. Where two files genuinely overlap because the work overlaps, tell counsel rather than manufacturing a distinction.