Expert Report vs. Deposition Audit
Audit an expert's deposition against their report: new opinions, abandoned opinions, changed bases, and undisclosed reliance materials — exclusion-motion fuel.
By practice
Proving liability, causation, and the full measure of damages for an injured client. Every prompt below assembles with this practice's emphasis already composed in — pick a workflow and add only the assignment details needed, using neutral labels where possible.
Practice workflow set
The configured personal injury — plaintiff lens adds this practice context to the template: This work product supports plaintiff's case: establishing liability, causation, and the full measure of the client's damages.
CasePrompts composes that emphasis into every prompt for this practice. Here is one complete, copy-ready example: the “Build the treatment story from the records” workflow using medical records as the source type, with the personal injury — plaintiff emphasis already built in. It pastes into any AI tool as is.
Synthetic example: Names, dates, organizations, and matter details are fictional placeholders, not a real case record.
CONTEXT: You are a litigation support analyst assisting plaintiff's personal injury counsel in a motor vehicle negligence claim matter. The attached production is the medical records of Alex Morgan. The incident at issue occurred on January 15, 2025. The injuries and conditions that matter are: fault; notice; causation; damages. This work product supports plaintiff's case: establishing liability, causation, and the full measure of the client's damages. INSTRUCTIONS: Build a complete treatment chronology covering every encounter in the production — visits, imaging, procedures, therapy sessions, and telephone encounters. For each encounter capture: provider and facility; date of service; presenting complaints in the patient's words where recorded; objective findings; diagnoses exactly as stated in the record (do not supply diagnoses or codes the record does not state); treatment rendered; medications; work or activity restrictions; and the next-step plan. Separately and explicitly: 1. Flag every gap in treatment longer than 30 days. 2. Flag every reference to symptoms, injuries, or treatment pre-dating January 15, 2025. 3. Collect every causation statement — any provider language attributing or declining to attribute a condition to the incident — verbatim. In this engagement, additionally: Give particular weight to provider language on causation, permanency, impairment, and future care needs, and to consistent symptom reporting across providers over time. TEMPLATE — format your output exactly as follows: ## Chronology | Date | Provider / facility | Complaints | Findings | Diagnoses (as stated) | Treatment / meds | Restrictions | Cite | |---|---|---|---|---|---|---|---| ## Treatment gaps (> 30 days) | Gap | Last visit before (cite) | First visit after (cite) | |---|---|---| ## Pre-existing / prior history references | Date | Provider | Verbatim reference | Cite | |---|---|---|---| ## Causation statements (verbatim) | Date | Provider | Exact language | Cite | |---|---|---|---| ## Permanency & future care language (verbatim) | Date | Provider | Exact language | Cite | |---|---|---|---| EVIDENCE REQUIREMENTS: For every entry, cite provider, date of service, and the page or Bates number of the source record. Record diagnoses and causation language exactly as written — never normalize, upgrade, or infer a diagnosis, and never supply an ICD code the record does not contain. If a record page is illegible or an encounter is referenced but missing from the production, list it under a final heading "Missing or illegible — request from provider" rather than guessing at its contents. If the provided record does not support a requested finding, write "not found in the record." Do not infer or fill gaps from outside knowledge. The scope is limited to the requested task, stated issues, and provided record. Do not introduce outside subjects or sources. A human reviewer must verify every material statement and citation against the source record before relying on or sharing the output.
Every template in the library assembles like this for personal injury — plaintiff — open the builder and add only the assignment details needed, using neutral labels where possible, or read the Attorney's Guide to AI Prompting for the method behind it.
Worked examples — each pairs a template with this practice's emphasis, end to end.
Read the clean, general guide for each curated workflow below. To apply the Personal injury — plaintiff context to your own facts, use the builder actions above.
Audit an expert's deposition against their report: new opinions, abandoned opinions, changed bases, and undisclosed reliance materials — exclusion-motion fuel.
Draft the facts and damages narrative of a demand from the record itself — every sentence cite-backed, gaps flagged instead of papered over.
Align a witness's deposition against every prior statement, classify each conflict, and get a lock-in → confrontation cross sequence with dual cites.
The standing-rules prompt: paste this once at the start of a chat session and every answer after it comes cited, sourced, and honest about gaps.