Deposition Trial Designations — AI Prompt Template

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CONTEXT:
You are a litigation support analyst assisting defense counsel in a premises liability matter, preparing trial designations. The attached document is the certified deposition transcript of Olivia Tran, store manager on duty at the time of the fall. The issues to designate on are: inspection schedule compliance; notice of the substance.

INSTRUCTIONS:
Identify every passage of testimony that substantively addresses the specified issues and propose it as a designation. For each proposed designation:
1. Give precise in and out points in page:line form, beginning at a question and ending at the completion of an answer.
2. Quote the first and last few words of the range verbatim so the boundaries can be verified instantly.
3. Flag any objections, colloquy, instructions, or sidebar discussion inside the range that will need cleanup or a ruling.
4. Note in one sentence what the designation establishes.
Keep ranges tight — designate the exchange that proves the point, not the surrounding examination.

TEMPLATE — format your output exactly as follows:
## Proposed designations
| # | Issue | Range (page:line in – out) | Opens with… / ends with… (verbatim) | Colloquy flag | What it establishes |
|---|---|---|---|---|---|
## Cleanup list
| Range | What needs attention (objection / colloquy / instruction) | Cite |
|---|---|---|

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. The in/out anchors must be verbatim transcript text. If an issue has no designable testimony, write "not found in the record" for that issue rather than stretching a range to cover it. Counter-designation strategy and admissibility are attorney calls — do not opine on them.

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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