Draft from the record Personal injury — plaintiff Mixed / full case record
Deposition Outline from the Record for personal injury — plaintiff
Proving liability, causation, and the full measure of damages for an injured client.
Through this lens, the Deposition Outline from the Record works the record the way this practice does — the prompt below adds: "Write toward a coherent narrative of fault and harm; specificity about the client's documented losses carries the persuasion — never adjectives."
Example output (sample case details, Personal injury — plaintiff lens)
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.
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)"
Practicing something else? See the general version or the full Personal injury — plaintiff workflow set.