Taking the example of a pleading, you will start by naming the parties (perhaps on a notepad). You will then set out the major elements of what needs to be dealt with in the pleading. If there are sub-sections within those major elements, then you should set those out. This outline is not necessarily going to be in the same detail as you end up dictating it, however, the outline can give you the flow and the order in which you should dictate. Provided you have prepared the file appropriately, you should have sufficient knowledge of the details of the file to allow you to dictate without having to fill in too many blanks.
You can then take your outline and use that as a basis for the dictation of your more complex document.
It is important to remember for more complex documents that your dictation does not need to contain all of the information at the first draft stage. If there are lists of invoices, numbers, mathematical factors that need to be done that would disrupt your train of thought or divert you from having a cohesive and efficient process, then those can be put to one side. Instead, simply dictate a placeholder (for example – “the defendant owes the plaintiff the total sum of X dollars”). You can then come back to that at a later time once the document is closer to being finalised.
This is different to when you are dictating a short letter or an email where you are trying to produce something as close to a final product as possible. The purpose when dictating a longer or more complex document is to allow you to use dictation as a tool for getting the bulk of the work done in a short space of time. In more complex scenarios there will be a greater degree of attention required after the first draft is produced and it is likely that you will have a number of further drafts before the final document is completed. That is not a reason to avoid dictation, but rather it is reason to embrace dictating in such a way that maximises efficiency and productivity, rather than not doing it all.
Source: Tips for Lawyers