AI Deposition Outline Prompt from the Record for personal injury — plaintiff
Proving liability, causation, and the full measure of damages for an injured client.
This combination adds the published CasePrompts emphasis for the Personal injury — plaintiff practice category to the AI Deposition Outline Prompt from the Record: "Write toward a coherent narrative of fault and harm; specificity about the client's documented losses carries the persuasion — never adjectives."
Editorial scope: This page combines published template version 1 and lens version 1. No independent legal review is recorded. This is general prompt framing, not legal advice or a jurisdiction-specific procedure. Verify every output against the record and governing authority.
Worked example · Synthetic fictional details · Personal injury — plaintiff lens
Sample prompt
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, preparing to take the deposition of Jordan Lee, the defendant driver. The attached materials are the existing record relevant to this witness: the incident report, recorded statement, and deposition transcript. The examination must cover: fault; notice; causation; damages. 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. 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.
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)"
Practicing something else? See the general version or the full Personal injury — plaintiff workflow set. For source-specific citation and verification steps, use the full case records workflow.