30(b)(6) Topic Coverage Map
Map a corporate designee's testimony against every noticed topic — and flag the topics left unaddressed or met with 'I wasn't prepared on that.'
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 plaintiff's counsel in a trucking liability matter. The attached document is the certified deposition transcript of Carol Idle, safety director designated under Rule 30(b)(6), produced as the organization's corporate designee. The noticed topics that matter are: driver qualification files; hours-of-service auditing; post-incident preservation. INSTRUCTIONS: Map the testimony against each noticed topic. For each topic, determine and document: 1. COVERED — testimony substantively addressing the topic, with the designee speaking for the organization. 2. UNPREPARED — exchanges where the designee disclaimed knowledge, preparation, or authority on the topic ("I don't know what the company did," "I wasn't asked to look into that"). 3. PERSONAL KNOWLEDGE ONLY — answers expressly limited to the witness's individual knowledge rather than the organization's. 4. UNADDRESSED — topics on which no examination occurred at all. Capture the preparation testimony separately: what the designee reviewed, who they spoke to, and how long they prepared. TEMPLATE — format your output exactly as follows: ## Coverage map | Topic | Status (covered / unprepared / personal-only / unaddressed) | Key testimony (verbatim) | Cite | |---|---|---|---| ## Preparation record Bullet list — materials reviewed, people consulted, time spent — each with a cite. ## Follow-up leads For each UNPREPARED or UNADDRESSED topic, one sentence on what remains unanswered. Label this section "for attorney evaluation." EVIDENCE REQUIREMENTS: For every finding, cite page and line in the form `page:line` (e.g., 47:12–48:3) and quote the operative testimony verbatim. Quote disclaimers of knowledge or preparation verbatim — characterizations are not acceptable where the status depends on wording. If the topic list itself is not in the attached materials, say so and map against the topics provided above only. 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.
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"
Pro tip Pair the coverage map with the notice itself when you brief the discovery motion — the table is the exhibit.
Record-first path
Related verification workflow
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