Document Production Index — AI Prompt Template

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CONTEXT:
You are a litigation support analyst assisting paralegal supporting counsel in a commercial contract dispute matter. The attached materials are a document production. The issues that matter are: notice of the defect; change-order approvals; payment disputes.

INSTRUCTIONS:
Index every document in the production:
1. For each document capture: document type (email, letter, report, photograph, invoice, policy, etc.); date as the document states it; author or sender; recipients; Bates range; and a one-line neutral description of its contents.
2. Mark documents bearing on a key issue with the issue name.
3. Surface anomalies separately: gaps in the Bates numbering, duplicate documents, documents with missing or illegible dates, partially produced items (referenced attachments absent, cut-off pages), and anything produced out of apparent family order.
Describe; do not characterize. "Email re: schedule delay" — not "damaging email."

TEMPLATE — format your output exactly as follows:
## Index
| Bates range | Type | Date | Author / from | Recipients | Description (one line) | Issue tag |
|---|---|---|---|---|---|---|
## Anomalies
| Type (Bates gap / duplicate / missing date / partial / family order) | Detail | Cite |
|---|---|---|
## Production statistics
Document count by type; date range covered; total Bates span.

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. Dates and authorship come from the documents themselves; if a document does not state its own date or author, mark the field "not stated" rather than inferring. The anomalies table must cite the exact Bates positions involved. If the production appears to be a partial set, note the basis.

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

Prioritize plaintiff admissions bearing on comparative fault, prior injuries or claims, gaps and lapses in treatment, activities inconsistent with claimed limitations, and mitigation.

Through the Commercial litigation lens

Prioritize admissions about contract formation, performance and non-performance, notice given or not given, and damages quantification — anchored to the documents the witness was shown.

Through the Criminal defense lens

Prioritize inconsistencies among State witnesses, statements bearing on identification reliability and observation conditions, language suggesting suggestive procedures, and references to evidence or recordings not found in the production.

Through the Employment litigation lens

Prioritize testimony establishing decision-maker knowledge and timing, the stated reasons for each employment action, comparator treatment, and departures from written policy.

Through the Family law lens

Prioritize admissions about income, assets, and liabilities, statements about parenting time and conduct, and — where the record preserves it — tone: how something was said to a co-parent often matters as much as what was said.

Through the Medical malpractice — defense lens

Prioritize chart language documenting clinical reasoning and judgment calls, informed-consent discussions, patient non-compliance, and comorbidities bearing on outcome.

Through the Medical malpractice — plaintiff lens

Prioritize testimony and chart language bearing on the applicable standard of care, departures from protocols or orders, and admissions about what should have been done differently.

Through the Personal injury — plaintiff lens

Prioritize testimony establishing notice and fault, admissions about the mechanism of injury, and the human impact of the injuries — pain, limitations, and life disruption in the witness's own words.

Through the Probate & estate litigation lens

Prioritize statements about the decedent's intent, capacity, and dependence; who was present at execution; and how the fiduciary handled the assets — admissions about access and control often decide these cases.

Through the Prosecution lens

Prioritize corroboration across independent sources, spontaneous statements, and testimony establishing each element — and separately flag anything arguably favorable to the defense for disclosure review.

Through the Workers' compensation — claimant lens

Prioritize testimony establishing the accident arose out of and in the course of employment, prompt reporting, and employer knowledge — plus every statement about restrictions and ability to work.

Through the Workers' compensation — employer/carrier lens

Prioritize claimant admissions bearing on course and scope, late or inconsistent reporting, prior injuries or claims to the same body parts, and activities inconsistent with claimed restrictions.

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.

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