Draft from the record Mixed / full case record
Deposition Outline from the Record
Build an examination outline straight from the existing record: goals to lock in, exhibits keyed to questions, and sequences that end in commitment.
Example output (sample case details)
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.
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. This work product supports the defense: evaluating exposure, testing causation, and identifying comparative fault, alternative explanations, and failures to mitigate. 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. In this engagement, additionally: Maintain a neutral, evaluative tone appropriate for carrier reporting; keep established facts and the plaintiff's contentions visibly separate throughout. 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.
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. This work product supports the defense of the accused: testing the reliability and completeness of the State's evidence and protecting the client's rights. 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. In this engagement, additionally: Build examination sequences that commit witnesses to specifics before any confrontation, and never embed a factual premise the discovery does not contain. 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.
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. This work product supports a family law matter, where financial transparency and the statutory best-interests and equitable-distribution factors govern, and where the parties will often remain in each other's lives after judgment. 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. In this engagement, additionally: Keep the tone measured and factual; inflammatory framing reliably backfires in family court, and specificity does the persuading. 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.
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. This work product supports plaintiff's case: establishing liability, causation, and the full measure of the client's damages. 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. In this engagement, additionally: Write toward a coherent narrative of fault and harm; specificity about the client's documented losses carries the persuasion — never adjectives. 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.
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. This work product supports the prosecution: establishing each element of the charged offenses, anticipating defenses, and meeting disclosure obligations. 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. In this engagement, additionally: Build examinations that establish elements through specifics and anticipate the defense themes the record itself suggests. 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.
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 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 Family law lens
Keep the tone measured and factual; inflammatory framing reliably backfires in family court, and specificity does the persuading.
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 Prosecution lens
Build examinations that establish elements through specifics and anticipate the defense themes the record itself suggests.
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
- Your role
- Case type e.g., "trucking liability," "first-party property," "medical malpractice"
- Witness / deponent name e.g., "Dr. Alan Smith"
- Their role in the case e.g., "plaintiff's accident reconstructionist"
- Key issue(s) — 1 to 3 e.g., "vehicle speed at impact; brake maintenance; visibility"
- Prior statements / materials in play (optional) e.g., "recorded statement to adjuster (6/2/24); affidavit (9/1/24)"
Pro tip Print the exhibit list as your tabbing order — the outline and the binder stay in sync.
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