AI Deposition Outline Prompt from the Record
Turn the verified case record into a topic-based deposition outline with fact-locking goals, record-cited exhibits, conflict probes, and open-to-closed question sequences.
Direct answer
What is an AI deposition outline prompt?
It asks an AI tool to turn an existing case record into a topic-based examination plan. This prompt ties each factual premise and proposed exhibit to a source, moves from open questions to closed and lock-in questions, and marks unsupported assumptions for attorney confirmation rather than presenting them as facts.
When to use this prompt
- After the witness-specific record has been collected and reviewed, while counsel is organizing deposition objectives and exhibits.
- When prior statements, documents, and conflicting accounts need to be converted into sequenced examination topics.
- When a first-pass outline would help expose unsupported premises before counsel makes strategic and jurisdiction-specific revisions.
Record inputs to prepare
- The verified materials relevant to the witness, identified by document name and stable page, Bates, exhibit, or transcript cites.
- Prior testimony, written statements, discovery responses, correspondence, reports, and exhibits that may support or conflict with a premise.
- The witness name and role, case type, counsel role, and the issues the examination must cover.
- Counsel-supplied objectives and any governing limits that the record alone cannot establish.
Worked example · Synthetic fictional details
Sample prompt
Synthetic example: The names, dates, case details, and issues below are fictional CasePrompts sample values, not client data or evidence from a real matter. They demonstrate the prompt format, not the accuracy of any AI model's output.
Preview the complete sample prompt
CONTEXT: You are a litigation support analyst assisting defense counsel in a premises liability matter, preparing to take the deposition of Olivia Tran, store manager on duty at the time of the fall. The attached materials are the existing record relevant to this witness: incident report (Ex. 3); sweep logs (Ex. 7); plaintiff's deposition transcript. The examination must cover: inspection schedule compliance; notice of the substance; camera coverage. INSTRUCTIONS: Draft a deposition outline organized by topic. For each topic: state the goal as a fact to lock in (one sentence, phrased as the testimony we want committed to the record); list the foundation documents and exhibits to use, with cites to where each appears in the attached record; and draft a question sequence that moves from open questions to closed questions to a final lock-in question. Where the attached record contains statements by or about this witness that conflict with each other, build a dedicated topic to probe the conflict, citing both sides. Close the outline with a complete exhibit list in order of first use. TEMPLATE — format your output exactly as follows: ## Outline ### Topic 1: [name] - Goal (fact to lock in): … - Foundation exhibits: [doc, cite], … - Sequence: 1. (open) … 2. (closed) … 3. (lock-in) … [repeat per topic] ## Conflict probes Topic-formatted as above, each conflict citing both record sources. ## Exhibit list (in order of first use) | # | Document | Record cite | Used in topic | |---|---|---|---| EVIDENCE REQUIREMENTS: For every finding, identify the source document by name and cite page:line for transcripts, timestamps for audio/video, and Bates/page for documents. Every factual premise embedded in a question must trace to the attached record with a cite; if a question rests on an assumption the record does not support, mark it "[UNSUPPORTED — confirm before use]" instead of presenting it as established. Do not invent documents, dates, or events. This outline is a working draft for attorney revision, not a script. 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.
Through the Civil / insurance defense lens
Maintain a neutral, evaluative tone appropriate for carrier reporting; keep established facts and the plaintiff's contentions visibly separate throughout.
Through the Commercial litigation lens
Tie every factual premise to a document with a Bates cite; recollection unsupported by the record gets flagged, not adopted.
Through the Criminal defense lens
Build examination sequences that commit witnesses to specifics before any confrontation, and never embed a factual premise the discovery does not contain.
Through the Employment litigation lens
Build examination sequences that commit decision-makers to the reasons and the timing before any confrontation with the documents.
Through the Family law lens
Keep the tone measured and factual; inflammatory framing reliably backfires in family court, and specificity does the persuading.
Through the Medical malpractice — defense lens
Keep established chart facts and the plaintiff's allegations visibly separate, and let the contemporaneous documentation carry the persuasion.
Through the Medical malpractice — plaintiff lens
Write toward the causation chain — each clinical decision linked to its consequence — with provider language quoted verbatim and no medical conclusions the record does not state.
Through the Personal injury — plaintiff lens
Write toward a coherent narrative of fault and harm; specificity about the client's documented losses carries the persuasion — never adjectives.
Through the Probate & estate litigation lens
Keep it factual and element-driven; probate courts reward precision over heat, and a clean record cite persuades where adjectives do not.
Through the Prosecution lens
Build examinations that establish elements through specifics and anticipate the defense themes the record itself suggests.
Through the Workers' compensation — claimant lens
Write toward the statutory touchpoints — notice, causal connection, restrictions, wage loss — with provider and employer language quoted verbatim.
Through the Workers' compensation — employer/carrier lens
Maintain a neutral, evaluative tone appropriate for carrier reporting, keeping established facts and the claimant's contentions visibly separate.
AI output is a starting point, not work product. Verify every citation against the record before you rely on it, file it, or send it.
What you'll fill in
- 01Your role
- 02Case typee.g., "trucking liability," "first-party property," "medical malpractice"
- 03Witness / deponent namee.g., "Witness A" or "the treating physician"
- 04Their role in the casee.g., "plaintiff's accident reconstructionist"
- 05Key issue(s) — 1 to 3e.g., "vehicle speed at impact; brake maintenance; visibility"
- 06Prior statements / materials in play(optional)e.g., "recorded statement to adjuster (6/2/24); affidavit (9/1/24)"
Human review gate
Verification and common failure modes
- Trace every factual premise and proposed exhibit to its cited source; delete or rewrite any question the record does not support.
- Confirm that statements are attributed to the right person and that a summary, allegation, or attorney characterization is not recast as evidence.
- Read both sources behind each conflict probe and preserve material qualifications, dates, and context.
- Have responsible counsel revise ordering, phrasing, foundation, privilege, objections, and jurisdiction-specific procedure before use.
Boundaries
Limitations
- The output is a preparation draft, not a live script, legal advice, or a substitute for attorney strategy and judgment.
- An incomplete or poorly cited record can create unsupported premises, omit controlling context, or suggest an exhibit that is not available.
- The prompt cannot determine applicable law, ethical duties, admissibility, foundation, privilege, or the best examination tactic.
- CasePrompts does not receive the case file on this page; counsel must approve any third-party tool and its data-handling terms before using record material.
Keep working
Practice versions and related workflows
Provenance
Version and editorial method
- Published by
- CasePrompts, a DepoStack project
- Template
- Version 1
- Page updated
Editorial owner: Andrew Mayes. The versioned CITE content is validated at build time, and this page's sample is assembled deterministically from the synthetic values above. No language model generates the sample page.
Review status: This template has not received independent legal review. “Published” describes its CasePrompts release status; it is not a claim of legal approval, jurisdictional sufficiency, or measured model accuracy.
Read the editorial methodology →Pro tip Print the exhibit list as your tabbing order — the outline and the binder stay in sync.
Related templates
Demand Letter Facts Section
Draft the facts and damages narrative of a demand from the record itself — every sentence cite-backed, gaps flagged instead of papered over.
Requests for Admission Drafter
Draft Requests for Admission aimed at single facts the record already supports — one fact each, grouped by issue, plus authentication RFAs and the facts you still need.
Interrogatory Answer Support Builder
Gather the record facts and cites that support each interrogatory answer — facts only, gaps flagged, so the attorney drafts from evidence instead of memory.